Mooney v. Illinois Education Association

From Ballotpedia
Jump to: navigation, search
Mooney v. Illinois Education Association
Case number: 19-1126
Status: Closed.
Important dates
Filed: Dec. 6, 2018
District court decision:
April 11, 2019
Appeals court decision:
Nov. 5, 2019
Supreme Court declined:
Jan. 25, 2021
District court outcome
Unions are not liable to refund fair-share fees, because they acted in good faith under the law at the time of collection.
Appeals court outcome
Affirmed the decision of the lower court.
Supreme Court outcome
Petition for certiorari denied.

This case is one of over a hundred public-sector union lawsuits Ballotpedia tracked following the U.S. Supreme Court's 2018 decision in Janus v. AFSCME. These pages were updated through February 2023 and may not reflect subsequent case developments. For more information about Ballotpedia's coverage of public-sector union policy in the United States, click here. Contact our team to suggest an update.

Mooney v. Illinois Education Association was decided by a three-judge panel of the U.S. Court of Appeals for the Seventh Circuit on November 5, 2019. The panel upheld the U.S. District Court for the Central District of Illinois’s April 2019 dismissal of the suit, which sought refunds for fair-share fees collected from non-union members prior to the U.S. Supreme Court's 2018 ruling in Janus v. AFSCME. The plaintiff filed a petition for writ of certiorari before the Supreme Court on March 10, 2020. The Supreme Court declined to hear the case on January 25, 2021.[1]

HIGHLIGHTS
  • The parties to the suit: The plaintiff was Stacey Mooney, an Illinois public school teacher. The defendants were the Illinois Education Association, National Education Association, and the Congerville-Eureka-Goodfield Education Association.
  • The issue: Must unions refund fair-share fees collected from non-members prior to Janus?
  • The outcome: A three-judge panel of the U.S. Court of Appeals for the Seventh Circuit upheld the U.S. District Court for the Central District of Illinois’s decision. The lower court had dismissed the case, ruling that the defendants were entitled to a good faith defense.

    • Procedural history

    The plaintiff was Stacey Mooney, an Illinois public school teacher. She was represented by Mitchell Law PLLC. The defendants were the Illinois Education Association, National Education Association, and the Congerville-Eureka-Goodfield Education Association. They were represented by Bredhoff & Kaiser, PLLC.

    Mooney first filed her lawsuit on December 6, 2018, in the U.S. District Court for the Central District of Illinois. The suit sought to establish a class of all non-union members compelled to pay fair-share fees to the IEA or its affiliates and sought refunds for all fair-share fees collected prior to the U.S. Supreme Court's decision in Janus v. AFSCME.[2]

    • December 6, 2018: Mooney filed a complaint in the U.S. District Court for the Central District of Illinois.
    • February 19, 2019: The defendants filed a motion to dismiss, arguing that they acted in good faith under the law at the time of collection.
    • April 11, 2019: The court dismissed the suit, ruling that the defendants were entitled to a good faith defense.
    • April 23, 2019: Mooney appealed the court’s decision to the U.S. Court of Appeals for the Seventh Circuit.
    • May 27, 2019: Mooney filed an appellant brief.
    • June 26, 2019: The defendants filed an appellee's brief.
    • September 20, 2019: The appeals court heard oral arguments.
    • November 5, 2019: The court affirmed the decision of the lower court.
    • November 19, 2019: Mooney filed a petition for rehearing and rehearing en banc.
    • December 12, 2019: The court denied the petitions for rehearing.
    • March 10, 2020: Mooney filed a petition for writ of certiorari before the U.S. Supreme Court.
    • May 11, 2020: The defendants filed a brief in opposition.
    • June 9, 2020: Mooney filed a reply brief.
    • January 25, 2021: The Supreme Court denied the petition for certiorari.

    For a list of available case documents, click here.

    Decision

    U.S. District Court for the Central District of Illinois

    On April 11, 2019, Judge Joe McDade dismissed the suit, writing:

    “ The unions may not have spent Plaintiff’s funds as she would have, but there is no allegation that they failed to provide services as required by Illinois law to her or others similarly situated. Because the fair-share fees were expended on Plaintiff and others similarly situated, she would gain their benefit twice if legal restitution were allowed. Of course, had the fees not been spent for Plaintiff’s benefit—and thus been available through equitable restitution—the calculus might be different.

    The Court concludes the good-faith defense may be maintained in actions at law, and this action sounds in law rather than equity. Therefore, the good-faith defense is available here. The Court does not reach the question of whether it may be used in suits at equity. [2][3]

    		”

    McDade was appointed to the court in 1991 by President George H.W. Bush (R).

    U.S. Court of Appeals for the Seventh Circuit

    On November 5, 2019, a three-judge panel including Judges Diane Wood, Daniel Manion, and Ilana Rovner affirmed the lower court’s decision. Wood wrote the following in the court's opinion:

    “ On remand from the Supreme Court, Mr. Janus sought damages pursuant to 42 U.S.C. § 1983 in the amount of the fair-share fees he had paid prior to Janus. Mooney, in contrast, insists that she is not seeking damages, but instead that she is entitled to the equitable remedy of restitution under the same statute. From the point of view of the union, the two requests are identical: each one seeks a refund of the fees that the plaintiff paid under the ancien régime. Mooney, however, believes that there is something special about restitution that is outcome-determinative. Perhaps that is true in some situations, but as we now explain, in substance Mooney is also seeking damages, and so her claim must fail.[4][3] ”

    Wood was appointed to the court in 1995 by President Bill Clinton (D). Manion was appointed to the court in 1986 by President Ronald Reagan (R). Rovner was appointed to the court in 1992 by President George H.W. Bush (R).

    Legal context

    Janus v. AFSCME (2018)

    See also: Janus v. AFSCME

    On June 27, 2018, the Supreme Court of the United States issued a 5-4 decision in Janus v. American Federation of State, County, and Municipal Employees (Janus v. AFSCME), ruling that public-sector unions cannot compel non-member employees to pay fees to cover the costs of non-political union activities.[5]

    This decision overturned precedent established in Abood v. Detroit Board of Education in 1977. In Abood, the high court held that it was not a violation of employees' free-speech and associational rights to require them to pay fees to support union activities from which they benefited (e.g., collective bargaining, contract administration, etc.). These fees were commonly referred to as agency fees or fair-share fees.[5]

    Justice Samuel Alito authored the opinion for the court majority in Janus, joined by Chief Justice John Roberts and Justices Anthony Kennedy, Clarence Thomas, and Neil Gorsuch. Alito wrote, "Abood was poorly reasoned. It has led to practical problems and abuse. It is inconsistent with other First Amendment cases and has been undermined by more recent decisions. Developments since Abood was handed down have shed new light on the issue of agency fees, and no reliance interests on the part of public-sector unions are sufficient to justify the perpetuation of the free speech violations that Abood has countenanced for the past 41 years. Abood is therefore overruled."[5]

    Related litigation

    To view a complete list of the public-sector labor lawsuits Ballotpedia tracked between 2019 and 2023, click here.

    Number of federal lawsuits by circuit

    Between 2019 and 2023, Ballotpedia tracked 191 federal lawsuits related to public-sector labor laws. The chart below depicts the number of suits per federal judicial circuit (i.e., the jurisdictions in which the suits originated).

    Public-sector labor lawsuits on Ballotpedia

    See also: Public-sector union policy in the United States, 2018-2023

    Click show to view a list of cases with links to our in-depth coverage.

    v • e
    Public-sector labor lawsuits
    Federal lawsuits

    Adams v. Teamsters Union Local 429 • Akers v. Maryland State Education Association • Aliser v. SEIU California • Allen v. Ohio Civil Service Employees Association • Allen v. Santa Clara County Correctional • Anderson v. SEIU Local 503 • Babb v. California Teachers Association • Baisley v. International Association of Machinists and Aerospace Workers • Belgau v. Inslee • Bennett v. AFSCME • Bermudez v. SEIU Local 521 • Bierman v. Dayton • Boudreaux v. Louisiana State Bar • Boyle v. SEIU California • Brice v. California Faculty Association • California v. Azar • Campos v. Fresno Deputy Sheriff’s Association • Carey v. Inslee • Casanova v. IAM Local 701 • Chandavong et al. v. Fresno Deputy Sheriff's Association et al. • Cook v. Brown • Cooley v. California Statewide Law Enforcement Association • Crowe v. Oregon State Bar • Cruz v. Union Independiente Autentica de Empleados de la Autoridad de Acueductos y Alcantarillados • Danielson v. Inslee • Diamond v. Pennsylvania State Education Association • Doughty v. State Employees Association of New Hampshire, SEIU, Local 1984 • Durst v. OEA • Few v. United Teachers Los Angeles • File v. Hickey • Fischer v. Murphy • Fisk v. Inslee • Fizer v. Ohio Association of Public School Employees • Fleck v. Wetch • Grega v. Council of New Jersey State College Locals • Grossman v. Hawaii Government Employees Association • Gruber v. Oregon State Bar • Guppy v. City of Los Angeles • Halloran v. AFSCME Council 5 • Hamidi v. SEIU • Hannay v. Kent State • Hartnett v. Penn. State Education Association • Hendrickson v. AFSCME Council 18 • Hernandez v. AFSCME California • Hoekman v. Education Minnesota • Hough v. SEIU Local 521 • Imhoff v. California Teachers Association • Jackson v. Napolitano • James v. SEIU Local 688 • Janus v. AFSCME • Jarchow v. Wisconsin • Kabler v. United Food and Commercial Workers Union, Local 1776 Keystone State • Wenzig v. SEIU Local 668 • Kopie v. International Federation of Professional and Technical Employees • Kurk v. Los Rios Classified Employees Association • Lamberty et al. v. Connecticut State Police Union et al. • LaSpina v. SEIU Pennsylvania State Council • Lee v. Ohio Education Association • Leitch v. AFSCME • Littler v. Ohio Association of Public School Employees • Loescher v. Teamsters Local 320 • Lutter v. JNESO • Mandel v. SEIU Local 73 • Marsh v. AFSCME Local 3299 • Martin v. California Teachers Association • Masuo v. AFSCME AFL-CIO • Matthews v. United Teachers of Los Angeles • Mattos v. AFSCME Council 3 • Mayer v. Wallingford-Swathmore School District • McCain v. Ventura County Federation of College Teachers, AFT Local 1828 • McCollum v. NEA-Alaska • McCutcheon v. CWA Local 7076 • McDonald v. Firth • Mendez v. CTA • Miller v. Inslee • Misja v. PSEA • Molina v. SEIU Local 668 • Mooney v. Illinois Education Association • Nearman v. SEIU Local 503 • Neely v. AFSCME Council 13 • Nguyen v. Admin. and Residual Employees Union • Nichols v. Home Care Providers Union • O'Callaghan v. Drake • Ochoa v. Public Consulting Group • Ocol v. Chicago Teachers Union • Ogle v. Ohio Civil Service Employees Association, AFSCME, Local 11 • Oliver v. SEIU Local 668 • Pellegrino v. New York State United Teachers • Penning v. SEIU Local 1021 • Polk v. Yee • Popp v. ALPAI • Piekarski v. AFSCME Council 5 • Quirarte v. UDW AFSCME Local 3930 • Reisman v. Associated Faculties of the University of Maine • Rizzo-Rupon v. International Association of Machinists and Aerospace Workers, District Lodge 141 • Routh v. Inslee • Schaszberger v. AFSCME Council 13 • Schell v. Oklahoma Supreme Court Justices • Schumaker v. Inslee • Seager v. UTLA • Seidemann v. Professional Staff Congress • Smith v. AFSCME Council No. 8 • Smith v. New Jersey Education Association • Smith v. Bieker • Solomon v. AFSCME District Council 37 • Stroeder v. Service Employees International Union, Local 503 • Sweeney v. Raoul • Sweet v. California Association of Psychiatric Technicians • Taylor v. Heath • Thompson v. AFSCME Council 89, Local 4013 • Thompson v. Marietta Education Association • Thulen v. AFSCME • Uradnik v. Inter Faculty Org. • Utke v. University of Connecticut American Association of University Professors • Weyandt v. PSCOA • Wholean v. CSEA SEIU Local 2001 • Wilford v. National Education Association • Williams v. PSEA • Wolf v. University Professional & Technical Employees • Yates v. Hillsboro Unified School District • Yohn v. California Teachers Association

    See also

    External links

    Case documents

    Supreme Court

    Appeals court

    Trial court

    Footnotes

    1. ↑ Supreme Court of the United States, "No. 19-1126," accessed March 16, 2021
    2. ↑ 2.0 2.1 U.S. District Court for the Central District of Illinois, "Order & Opinion," April 11, 2019 Cite error: Invalid <ref> tag; name "Order1" defined multiple times with different content
    3. ↑ 3.0 3.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    4. ↑ United States Court of Appeals for the Seventh Circuit, "Appeal from the United States District Court for the Central District of Illinois. No. 1:18-cv-1439-JBM — Joe Billy McDade, Judge," November 5, 2019
    5. ↑ 5.0 5.1 5.2 Supreme Court of the United States, Janus v. American Federation of State, County, and Municipal Employees, Council 31, et al., June 27, 2018
    v • e
    Public-sector union policy in the United States
    Public-sector union policy in the United StatesBPstarlogo.png
    Retrieved from "https://ballotpedia.org/wiki/index.php?title=Mooney_v._Illinois_Education_Association&oldid=9203465"